Corporate Governance

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● Governance Structure

In order to establish good corporate governance practices ensure the sound operation and achieve the goals of sustainable development, SinoPac Holdings has established the Corporate Governance Guidelines in accordance with the “Corporate Governance Best Practice Principles for Financial Holding Companies” and the “Corporate Governance Best Practice Principles for TWSE/TPEx Listed Companies” for SinoPac Holdings and its subsidiaries to comply with.

SinoPac Holdings has set up three functional committees including the Remuneration Committee, Audit Committee, and Ethical Corporate Management Committee. Its composition, responsibilities and operations are stipulated in the organizational charter of the respective committees.

 ● Shareholding Structure

  • SinoPac Holdings discloses its shareholder structure as shown in the table below. Shares held by government entities account for less than 5%.

  • Percentage of Shares Held by Family Members

More than 5% of the shares of the Company is held by the substantial shareholder S.C. Ho and the companies which he holds more than 50% of the shares. S.C. Ho and the same related party declared their holding of 20.39% of SinoPac’s shares on March 31, 2020 (major shareholders and the same related party with more than 10% of shares). Please refer to the "inquiries on the reports on the change of shareholding by major shareholders of banks (financial holding companies)" on the Market Observation Post System.

● Composition and Operations of the Board of Directors

  • Composition of the Board of Directors

SinoPac Holdings conducted re-elections of all Directors in the general shareholders’ meeting on May 13, 2020. The Board of Directors consists of seven Directors including one Executive Director (Director Stanley Chu who serves concurrently as the President of SinoPac Holdings), and six non-executive Directors, of which three are Independent Directors. Directors serve three-year terms. Among the six non-executive Directors, five serve concurrent roles in other companies. They serve concurrently in no more than four companies. The average tenure of the seven Directors as of May 13, 2020 was 2.4 years. The nomination and election of board members is not restricted by age or gender, and the main criteria include professional skills, integrity, and reputation in society. The current Board of Directors includes one female member and six male members with an average age of more than 55 years old. The members include three PhDs and four masters with diverse backgrounds and experiences. The diverse composition of the Board of Directors optimizes the decision-making process of the Board of Directors. The Company values gender equality of the members of the Board of Directors and aims to have at least one female Director which was achieved in 2020 by electing Ms. Shi-Kuan Chen as the Chairman on May 13, 2020. SinoPac Holdings thus became the first private financial holding company with a female Chairman.

  • Operations of the Board of Directors

The election of the Board of Directors of SinoPac Holdings is conducted via a candidate nomination system in which the shareholders vote on a group of candidates nominated at shareholders' meetings. The professional qualifications, restrictions on retention of shares and concurrent positions held, assessment of independence, method of nomination and election and other relevant requirements are reviewed for Independent Directors in accordance with related regulations. SinoPac Holdings specified in the Articles of Incorporation that all Directors serve a three-year term and may be re-elected. If new Directors have not been promptly elected upon expiration of the term of current Directors, the term of current Directors shall be extended until new Directors are elected and take office. To enhance corporate governance, SinoPac Holdings regularly compiles related continuing education courses on corporate governance in the current year for Directors and help them make arrangements for attending the courses.SinoPac Holdings group of companies has purchased the liability insurance for directors, supervisors, and managers since 2003 and reviewed the contents of insurance policies each year. The Company uses the Market Observation Post System, corporate website, and annual reports to disclose the Directors' education/training and attendance in the Board of Directors. Major resolutions are disclosed in the Annual Report as well as recusals of Directors from agenda items due to conflicts of interests to improve information transparency in the operations of the Board of Directors.

  • Performance Evaluation of the Board of Directors

SinoPac Holdings has established the Regulations Governing the Evaluation of the Performance of the Board of Directors in 2018 to implement corporate governance and enhance the functions of the Board of Directors. The performance of the Board of Directors and functional committees should be evaluated according to the evaluation procedures and indicators set forth in the Regulations on an annual basis. The performance evaluation of the Board of Directors and functional committees shall be conducted by an external professional independent institution or a team of external experts and scholars at least once every three years, and the results of performance evaluation shall be reported to the Board of Directors before the end of March in the following year.

●Sustainable Development Committee

SinoPac Holdings established the "CSR Project Team" in 2015 to actively plan CSR related affairs. In 2018, the Company established the "Guidelines for Corporate Social Responsibility", actively responded to international sustainability trends and implemented corporate social responsibilities of the financial industry. SinoPac Holdings also established the "Sustainable Development Committee" in March of the same year. The Chairman of SinoPac Holdings serves as the chairperson of the Committee, with the President of SinoPac Holdings and the chairmen and presidents of major subsidiaries serving as members. The Committee oversees five task forces responsible for corporate governance, customer relations, employee welfare, social involvement, and environmental protection. The committee is in charge of managing the risks and impacts of operations of SinoPac Holdings and its subsidiaries on the economy, environment, and society, and establishing CSR Policy, systems, and related management plans and submit them to the Board of Directors to implement corporate social responsibility.

● Remuneration Policy for Senior Executives

The remuneration for the President and Vice President (senior executives) of SinoPac Holdings is based on their individual professional qualifications and experience and the prevailing rates in the industry, discussed in the remuneration committee and then submitted to the Board of Directors for approval. In addition to the fixed monthly base salary and allowances, a variety of bonuses may be paid according to the Company's rules with consideration of the overall annual business performance, personal performance, and future risks. All performance bonuses are distributed in cash, of which 10% will be retained and deferred to pay in the next three years. This scheme creates a close link between the remuneration for the management and the performance of the Company and ensures investor benefits.

To balance short-term and long-term remuneration, business performance and personal performance, and cash and non-cash remuneration, SinoPac Holdings established the Long-Term Incentives and Remuneration Program, and designed the deferred distribution of the performance bonus (up to 5 years) by way of virtual shares and employee stock ownership that connected to the value of the shares of SinoPac Holdings, so that the remuneration of managerial officers is closely connected to the short-term business performance and long-term development of SinoPac Holdings. The conditions for unlocking medium to long-term incentives in the trust scheme include the financial performance of SinoPac Holdings and it subsidiaries (e.g., ROE), effectiveness of the implementation of long-term strategies, TSR shareholder value and risk management, and corporate governance targets. They connect managerial officers' obligations and responsibilities to long-term performance.

 

Integrity Management and Legal Compliance

● Culture of Integrity Management

SinoPac Holdings established the "Ethical Corporate Management Committee" in 2018 and became the fifth financial holding company in Taiwan to establish an Ethical Corporate Management Committee. SinoPac Holdings also established the Whistleblowing Policy in the same year to complete the establishment of internal and external whistleblowing system. The Legal & Compliance Division is responsible for processing all reports and maintaining the confidentiality of whistleblowers and the contents of their reports. It also pledges to protect whistleblowers from inappropriate disciplinary actions as a result of whistleblowing. If whistleblowers are subject to inappropriate disciplinary actions due to their reporting, they may lodge a complaint with the Ethical Corporate Management Committee of SinoPac Holdings. The "Ethical Corporate Management Committee" consists of eight members including the Independent Directors of SinoPac Holdings, Bank SinoPac, and SinoPac Securities. Meetings are convened at least once every six months. The Committee is responsible for the review of the ethical corporate management policies and prevention programs, and for supervision of the implementation performance of the managerial departments. The Committee also regularly reports their compliance status and resolutions to the Board of Directors.

● Tax Policy

SinoPac Holdings mainly operates in Taiwan. In 2019 and 2018, the percentage of net revenues from Taiwan were 84.3% and 83.9%, respectively. Except for Taiwan, no more than 10% of the net revenues came from other countries. SinoPac Holdings complies with tax regulations and pays all taxes within the statutory tax-paying period. The income tax paid in 2019 and 2018 were NT$ 1,465,893 thousand and NT$1,429,954 thousand in which the percentage of income tax paid in accordance to Taiwan tax laws were 88.7% and 87.1%.

● Anti-Money Laundering and Financial Crime Prevention

SinoPac Holdings is committed to the establishment of comprehensive and effective anti-money laundering and counter terrorism financing mechanisms. It has established the Anti-Money Laundering and Counter Terrorism Financing Policy ("AML/CFT Policy") for compliance by SinoPac Holdings and all subsidiaries. The subsidiaries also established their own internal regulations and operating procedures for anti-money laundering and counter terrorism financing based on laws for their respective industries, related industrial laws and regulations, the self-disciplinary regulations and conventions of industry associations, and references provided in the AML/CFT Policy of SinoPac Holdings, and such internal policies shall address the following principles: customer identity verification, customer acceptance, customer and transaction monitoring, risk management, and record keeping.

● Material Violations and Improvement Measures

The management levels and employees of SinoPac Holdings and its subsidiaries are fully aware that they are the foundation for corporate sustainable governance. However, suitable improvements must be made based on the conditions and processing methods for incidents and adopted as lessons for optimizing corporate governance decision making in the future. The material violations in 2019 included a fraud case involving a former wealth management specialist of Bank SinoPac and a violation of internal regulations at SinoPac Futures. Total penalties amounted to NT$12.24 million, and the personnel associated with the cases were dismissed or issued warnings based on the severity of the violation. To continue to increase employees' compliance awareness, Bank SinoPac established the Employee Service and Code of Conduct Guidelines on November 11, 2019 in accordance with the Employee Service Guidelines of SinoPac Holdings and the Internal Control Principles for the Prevention of Misappropriation of Client Funds by Wealth Management Specialists of the Bankers' Association. The Guidelines of Bank SinoPac included important compliance matters such as the requirements for fiduciary duties, ethical conduct, and personal data protection. Training is organized each quarter starting from November 2019, and employees are required to sign statements each year to confirm compliance.

 

Risk Management

● Risk Management Structure

SinoPac Holdings has established a clear risk management structure consisting of four specialized layers, including the Board of Directors, the Risk Management Committee, the Risk Management Division, and the Audit Division from top to bottom. This clearly distinguishes the authorities and responsibilities, hierarchical authorization, and fully defines the management rules and limits for each risk to attain the optimal balance between profitability and risk management.

The Risk Management Committee was set up under the Chairman, who serves as the convener of the committee, to take charge of deliberating on the risk management policies, organization structure, systems and overall limits, reviewing the overall risk exposure, supervising the risk management activities of SinoPac Holdings and its subsidiaries, and coordinating efforts to manage material risk incidents.

The Risk Management Division was established under the President of SinoPac Holdings, to be responsible for the development of SinoPac Holdings' overall risk management policies and guideline as well as the planning and implementation of the risk management system. The policies, guideline and systems are approved by the Board of Directors and implemented by the Risk Management Division, which conducts regular evaluations in the performance of all subsidiaries in terms of risk management. SinoPac Holdings and its subsidiaries shall designate responsible units or personnel to take charge of risk management tasks in accordance with the business operations and the types and scale of risk exposure to ensure that all risk exposures are properly monitored.

 

  • Auditing Mechanisms

SinoPac Holdings has established a chief audit system and established Audit Division under the Board of Directors in accordance with the Implementation Rules of the Internal Audit and Internal Control System of Financial Holding Companies and Banking Industries. The Audit Division maintains its independence in performing auditing affairs and provides suggestions for improvements in due time to ensure the continuous and effective implementation of the internal control system and to provide a basis for the review and modification of the internal control system. The Audit Division conducts at least one regular business audit on SinoPac Holdings each year and conducts one special business audit in the finance, risk management, and compliance of SinoPac Holdings and its subsidiaries at least once every six months. It also reports the implementation of audits to the Board of Directors and Audit Committee at least once every six months.

  • Risk Management Policy

SinoPac Holdings has adopted an appropriate set of risk management organizational structure, management standards, control mechanisms, risk management report system, and a sound risk management culture to integrate the management of crucial risks and review and amend management mechanisms or measures when necessary. The Company establishes comprehensive risk regulations and limits to prevent the occurrence of material risk incidents to attain the optimal balance between profitability and risk management.

●Credit, Market, Operation, and Liquidity Risk Management

SinoPac Holdings and its subsidiaries have established management and assessment mechanisms for four major types of risks including credit risks, market risks, operational risks, and liquidity risks. In addition to rigorous compliance with credit risk management regulations, SinoPac Holdings is also aware of the potential impact of ESG trends on the finance industry and loan businesses. SinoPac Holdings thus actively responds to international standards, incorporates ESG indicators into the credit analysis and implements more comprehensive management of hidden risks in loan businesses to fulfill its social responsibility.

● Emerging Risk Management

Climate change and population structure changes may cause material impacts on the overall business environment. Effective identification and assessment of emerging risks and formulation of response measures have become important tasks for financial institutions. Accordingly, SinoPac Holdings established the Emerging Risk Management Guidelines in 2019 and management mechanisms for the identification, measurement, monitoring, reporting, and response measures for emerging risks.

  • Emerging Risk Identification Procedures and Results

The Risk Management Division of SinoPac Holdings references related reports on emerging risks published by external institutions each year and provides subsidiaries with information for annual assessments of emerging risks. The Division then compiles information on the emerging risks from all subsidiaries, identifies emerging risks at the group level, and plans response measures to the management levels for advanced preparation and response.

  • Emerging Risk Identification Results in 2019

  • Response to Major Risk Events

In response to the COVID-19 pandemic that started in early 2020, SinoPac Holdings supported the Central Epidemic Command Center’s policy and initiated emergency response and management mechanisms to safeguard the health and safety of all employees during the pandemic. When the outbreak first began, SinoPac Holdings established a COVID-19 Command Center to plan disease prevention strategies and real-time reporting mechanisms, maintain the safety of office premise, and monitor employee health. The center also promoted health management and disease prevention measures to all employees, and began planning and formulating backup measures, implementing work from home drills and testing. The center monitors daily outbreak reports and immediately adjusts its response strategy.

As the outbreak situation began to worsen, SinoPac Holdings implemented the phase II “business continuity plan”. SinoPac Holdings preemptively began working with Microsoft in March 2020 to become the first financial institution in Taiwan to use Windows Virtual Desktop services for working from home. In doing so, SinoPac Holdings hoped to jointly prevent the outbreak together with all employees through groups that take turns working in the office, remote backup, work from home, and flexible work hours, ensuring that customers receive as high quality services as before. SinoPac Holdings also implemented the employee holiday travel reporting mechanism in April 2020 to monitor the health condition of employees and avoid the risk of cluster infection. The work area of employees who were quarantined due to contact with a confirmed case was sterilized to reduce the probability of the virus surviving. During the epidemic, no employees of SinoPac Holdings were diagnosed with COVID-19, nor did any employees infect each other.

In addition to policy responses, SinoPac Holdings also took numerous measures to care for employee health during the epidemic, including providing health products to pregnant employees free of charge, caring for employees’ health, and extending the deadline to apply for marital leave. SinoPac Holdings also actively assisted employees in adapting to the remote and digital work model. Besides preparing an online meeting teaching manual for working remotely, office equipment was also upgraded to help employees communicate and continue to learn. The COVID-19 outbreak did not affect SinoPac Holdings' employee recruitment or separation, nor did it affect procurement from suppliers.

● Management Policy and Response Strategies for Climate-Related Risks and Opportunities

According to the World Economic Forum's Global Risks Report 2020, climate-related risks have dominated the rankings for the fourth consecutive year, in which “extreme weather” has been on the list for 7 consecutive years and ranked top1 risk for 4 consecutive years, while “natural disasters” have ranked in the top 3 over the past 4 years. SinoPac Holdings understands that climate change will create great risks as well as opportunities for companies at the same time, and therefore takes climate-related risks very seriously. Besides conducting periodic evaluations of TCFD and managing climate-related risks, it also keeps an eye on the opportunities arising from climate change.

  •  Governance Framework for Climate-Related Risks and Opportunities

The Sustainable Development Committee of SinoPac Holdings stays up-to-date on domestic and overseas trends in sustainable development issues and climate change, formulate sustainability guidelines. The task forces under the committee have formulated action plans corresponding to the commitment to Mitigate and Adapt to Climate Change: the Corporate Governance Task Force is responsible for implementing the TCFD framework, and includes scenario analysis and financial quantification on transition/physical risks of climate change as its mid- and long-term goals; the Customer Relations Task Force is responsible for supporting the development of the renewable energy industry through products and services, developing green sustainable finance, and striving to raise customers’ climate awareness; the Environmental Protection Task Force is responsible for GHG and energy management, taking climate change mitigation action in daily operations; the Employee Welfare Task Force and Social Involvement Task Force are responsible for organizing internal and external education and training sessions and seminars to raise the climate awareness of employees and the public.

  • Management Procedures for Climate-Related Risks and Opportunities

SinoPac Holdings follows the TCFD guidelines to improve management mechanisms of SinoPac Holdings and its subsidiaries for climate-related risks and opportunities, and to establish management procedures for climate-related risks and opportunities. Management procedures can be divided into four steps including compiling a list of risks and opportunities, identifying risks/opportunities of subsidiaries, identifying risks/opportunities at group level and proposing response strategies, and disclosing climate-related risks/opportunities and response strategies.

● Human Rights Risk Management

  • Human Rights Policy

SinoPac Holdings recognizes and supports the principles set forth in UN Universal Declaration of Human Rights, UN Guiding Principles on Business & Human Rights, UN Global Compact, and International Labor Organization Convention, and established the Human Rights Policy in 2018, emphasizing workplace human rights, providing a healthy and safe workplace, and respecting employees' freedom of association. The policy is applicable to SinoPac Holdings, subsidiaries it has substantial control over, and suppliers, and prevents any behavior that infringes on or violates human rights by establishing suitable management methods and procedures. SinoPac Holdings also regularly reviews risks in employee health and safety and implements improvement plans based on identification results. In the future, SinoPac Holdings will continue to monitor developments in the human rights policy of domestic and overseas companies and changes in the business environment, and carry out review and improvements accordingly.

In addition to internal management based on the human rights policy, SinoPac Holdings also requires its suppliers to fulfill their corporate social responsibility and respect international conventions on human rights. Besides selecting business partners and suppliers who comply with the spirit and basic principles of the human rights policy, SinoPac Holdings also established Supplier Corporate Social Responsibility Code of Conduct and urged the suppliers that it frequently does business with to sign the Supplier Corporate Social Responsibility Commitment and adopt consistent principles including respecting labor human rights, banning discrimination, banning child labor, occupational safety and health, environmental protection, procuring products with environmental certifications, business ethics and integrity management, aiming toto find a balance between the economy, society, environment, and ecology and achieve environmental sustainability. SinoPac Holdings periodically conducts on-site audits of the finances and manufacturing environment of suppliers, and builds long-term partnerships with suppliers that achieve good performance. Suppliers found in violation may even lose their supplier qualifications.

  • Human Rights Assessment Process and Results

SinoPac Holdings in 2019 collected the opinions of major stakeholders, both upstream and downstream, on human rights risks, and identified material human rights issues of SinoPac Holdings based on severity and frequency of the issues. Stakeholders identified through the questionnaire include employees, suppliers, and customers. A total of 121 questionnaires were collected, and the material human rights issues of SinoPac Holdings that were identified included labor conditions, privacy, dignity, forced labor, and health right. In order to strengthen human rights risk management and create a better workplace environment, SinoPac Holdings plans corresponding human rights risk mitigation and remedial measures and will conduct due diligence for human rights risks in the next 1-2 years.

 

● Risk Culture and Management

To ensure the effectiveness and quality of risk management, the Risk Management Division of SinoPac Holdings evaluates the implementation status of risk management by subsidiaries each year in the aspects of Risk Management Mechanisms, Risk Management Awareness Education and Training, and Risk Incident Reporting. The results of assessments are used as the basis for determining the annual performance of subsidiaries. Performance evaluations for risk management personnel of SinoPac Holdings and subsidiaries are based on the Employee Evaluation Guidelines, and a rating is assigned to each employee based on his/her annual work performance, goal attainment, and attendance. Furthermore, for the management of overall risks of SinoPac Holdings and subsidiaries, approval is required from the head of SinoPac Holdings' Risk Management Division when appointing, dismissing, promoting, rewarding/punishing, or evaluating the head of the Risk Management Division at each subsidiary and personnel at the Risk Management Division of SinoPac Holdings.

 

Information Security

● Information Security Governance Framework

Due to the rampant cyber-crime caused by emerging technologies, financial institutions must more cautiously respond to information security issues. Among the Board members of SinoPac Holdings, Mr. Yeh Chi-Hsing, who has a background in information security, is responsible for supervising the Group's information security strategies. The Information Security Committee was established under the president of SinoPac Holdings in September 2018, and is the highest level unit responsible for information security management. The committee is responsible for information security implementation and governance, and information security risk supervision and management. Sean Lee, who previously worked at the Criminal Investigation Bureau High-tech Crime Center and National Police Agency Information Management Office, serves as the convener of the committee. Committee members include the heads of the Compliance Division, the Risk Management Division, the Digital Technology Division, and information security related supervisors at subsidiaries; the chief auditor is invited to attend committee meetings. The Committee's responsibilities are to review the information security policy and regulations, review the information security management system, raise information security awareness, formulate related education and training plans, and evaluate and decide on information security related infrastructure. Bank SinoPac and SinoPac Securities have established dedicated information security units in accordance with the information security policy of SinoPac Holdings, and continue to update ISO 27001 Information Security Management certificate to fulfill their responsibility to maintain the confidentiality of customers or investors' personal information.

● Information Security Management

  • Information Security Policy

SinoPac Holdings established a safe and reliable IT system to strengthen information security management, and ensure data, system, equipment, and network security. SinoPac Holdings established the Information Security Policy to ensure that information processing at SinoPac Holdings and subsidiaries complies with information security related regulations, in order to protect customers' rights and interests. To ensures the implementation of the information security management system, SinoPac Holdings will amend its internal regulations in coordination with amendments to information security related laws in 2020, and reinforce information security plans and operating procedures including IT system security management, network security management, application system access management, application system development, maintenance, and management, computer asset management, system environment security management, and IT system disaster recovery management. . Furthermore, each year SinoPac Holdings reviews if the Information Security Policy and information security incident response procedures are suitable for the business environment and comply with the competent authority's regulatory requirements. SinoPac Holdings also evaluates material information security issues, analyzes the Group's internal information security risks and vulnerabilities, and announces the internal Information Security Policy to all employees via e-mail. Regular education and training are provided each year to improve employees' knowledge of information security. SinoPac Holdings sets forth business ethics and information privacy rules in the Supplier Corporate Social Responsibility Code of Conduct, and requires suppliers to reasonably protect business information and personal data to ensure the Company and individual privacy is not damaged due to data leakage. Also, suppliers may not disclose their relationship with SinoPac Holdings in any form without written consent from SinoPac Holdings. The Procurement Management Guidelines also clearly state that suppliers awarded contracts by SinoPac Holdings should not violate the Supplier Corporate Social Responsibility Code of Conduct.

  • Information Security Management Process and System

The system management, application software development, outsourcing management, database management, network management, information security management, and infrastructure maintenance by the information related units (including information security units) of Bank SinoPac and SinoPac Securities all comply with and have obtained ISO 27001 certification. This is to prevent IT systems from being hacked and personal data leakage due to improper design of the information security framework, or inadequate control from system, network, and privacy management mechanisms, which will affect the Company's information security. SinoPac Holdings will continue to maintain its ISO 27001 Information Security Management System certification, and strengthen the information security mechanisms and personal data protection and management in the aspects of APT defense system, defense against DDoS attacks, e-mail content filtering, malware detection, website and app vulnerability scanning, and security inspections. SinoPac Holdings also isolated and strengthened the security of high risk systems (such as ATM and SWIFT systems). SinoPac Holdings did not receive any fines or sustain any financial losses due to data leakage incidents or accidental damages to IT systems or equipment in 2019.

● Information Security Training and Education

Every corporate is responsible for improving its information security level, implementing information security in the business operation process, continuously enhancing employees’ awareness on information security, and building up an environment that emphasizes both service efficiency and security protection. To improve information security, SinoPac Holdings delivers updates of its internal security policies to all employees via email and have it announced on the intranet at all times; the compliance with information security has also been included in the employee performance evaluation. In addition, SinoPac Holdings actively addresses the importance of information security and establishes employee’s awareness towards information security through information security education and training for different functions of employees.

● Customer Information Privacy

Ensuring customers’ personal data privacy and financial information is the responsibility of each financial institution, and all financial institution should effectively manage and disclose their privacy management performance. In recent years, privacy protection has become increasingly important due to the development of diversified businesses. How to legally collect, process, and utilize data from customers within the scope of authorization and the establishment of a control mechanism to ensure the confidentiality of customer’s information and customer privacy has become a major issue for all companies in the financial industry.

In order to protect customers' personal data and privacy, SinoPac Holdings has established related management policies. Bank SinoPac, SinoPac Securities, SinoPac Securities (Europe), and SinoPac Securities Investment Trust appointed Data Protection Officers (DPOs), disclosed Customer Information Confidentiality Measures on their websites including the methods for the collection, storage, safekeeping, and protection of customer information and provide customers with rights to exercise and withdraw from information exchange and usage.

SinoPac Holdings values technological development, social environment and legal changes, and adjusts customer information confidentiality regulations from time to time and report them publicly. In order to implement personal information protection measures, each subsidiary has set up personal data protection management workforce to promote and review tasks and management plans regarding to personal data issues. Meetings are also held for the discussion or reporting of related topics when needed.